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" In Bethlehem Copper Corporation Ltd (74 DTC 6520), the Supreme Court stated that "... there is a mine within the meaning of s. 83(5) if there is a body of ore together with the workings, equipment and machinery capable of producing it. ...

The meaning of disposition of property has been interpreted broadly in Olympia & York 80 DTC 6185 (FCA) and Robert Bédard 85 DTC 643 (TCC) to include transactions or events that are not sales. ...

Comments We maintain the view expressed in our document dated September 13, 2000 (# 2000-0042885) that a derivative agreement such as a swap or forward contract is a contractual arrangement separate from any associated asset or liability for which it may be designed to hedge. ...

Our understanding of the relevant definitions, the facts, proposed transactions and the purpose of the proposed transactions is as follows: Definitions "A Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "Act" means the Income Tax Act (Canada), and unless otherwise stated, every reference herein to a part, section, subsection, paragraph or subparagraph is a reference to the relevant provision of the Act; "arm's length" has the meaning assigned by section 251; "B Co Companies" means XXXXXXXXXX; "C Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; "capital property" has the meaning assigned by section 54; "CCRA" means Canada Customs and Revenue Agency; XXXXXXXXXX; "D Co" means a trust established in XXXXXXXXXX pursuant to the laws of XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX; "D Co XXXXXXXXXX" mean XXXXXXXXXX units of beneficial interest in the D Co, XXXXXXXXXX; "D Co XXXXXXXXXX Ruling" means the advance income tax ruling XXXXXXXXXX issued by the CCRA on XXXXXXXXXX; "D Co XXXXXXXXXX Securities" mean D Co XXXXXXXXXX Securities, XXXXXXXXXX, as described in paragraph XXXXXXXXXX hereof; "D Co XXXXXXXXXX Securities" mean D Co XXXXXXXXXX Securities, XXXXXXXXXX, as described more fully in paragraphs XXXXXXXXXX and following hereof; "D Co XXXXXXXXXX " means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "Debenture Redemption Price" has the meaning set out in paragraph 39 hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "E Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "E Co XXXXXXXXXX" has the meaning set out in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "F Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; "G Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; "H Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; "I Co" means XXXXXXXXXX as described more fully in paragraph XXXXXXXXXX hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "prescribed stock exchange in Canada" has the meaning assigned by section 3200 of the Regulations; "principal amount" has the meaning assigned by subsection 248(1); "Proposed Transactions" means the transactions described in paragraphs 26 to 56 hereof; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; XXXXXXXXXX; "Regulations" means the Income Tax Regulations promulgated under the Act; XXXXXXXXXX; "subsidiary controlled corporation" has the meaning assigned by subsection 248(1); "subsidiary wholly-owned corporation" has the meaning assigned by subsection 248(1); XXXXXXXXXX; XXXXXXXXXX; "taxable Canadian corporation" has the meaning assigned by subsection 89(1); "taxable dividend" has the meaning assigned by subsection 89(1); XXXXXXXXXX; XXXXXXXXXX; Facts 1. ...

CAVEAT These rulings are provided subject to the general limitations and qualifications set out in Information Circular 70-6R5 issued by the Canada Customs & Revenue Agency (the "Agency") on May 17, 2002, and are binding provided that the proposed transactions are completed on or before XXXXXXXXXX. ...

The taxpayer referred to two documents (#9032185 and # 2002-0152203) issued by the Canada Customs and Revenue Agency (the "CCRA") to support their arguments. ...

The minimum amount which can be deferred is ten percent (10%) and the maximum is thirty three and one third percent (33 1/3 %). ...

Section 6700 of the Regulations includes corporations registered under various provincial or territorial statutes as well as registered LSVCCs ("RLSVCCs "). ...

To the best of your knowledge, and that of the taxpayer involved, none of the issues contained herein is: (i) dealt with in an earlier return of the taxpayer or a related person; (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person; (iii) under objection by the taxpayer or a related person; (iv) subject to a ruling previously issued by the Income Tax Rulings & Interpretations Directorate; or (v) before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...

. \ XXXXXXXXXX 992307 Attention: XXXXXXXXXX XXXXXXXXXX, 1999 Dear Sirs: Re: Advance Income Tax Ruling XXXXXXXXXX XXXXXXXXXX XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above noted taxpayers in respect of the income tax consequences arising out of the proposed transactions described below. ...